On December 29, 2016 the federal bank regulatory agencies announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. The annual adjustments are required by the CRA rules. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small institution asset-size thresholds are not […]
Month: December 2016
CONSUMER COMPLIANCE RATING SYSTEM REVISIONS – WE’RE FROM THE GOVERNMENT AND WE’RE HERE TO HELP YOU!
On November 7th, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (“CCRS”). The press release that accompanied the revision stated that the document was intended to “more fully align the rating system with the FFIEC agencies current risk-focused, tailored examination approaches” and that “the rating system’s adoption will represent no additional regulatory burden for financial institutions”. Or does it? So, far so good as we’ve all long known, through various […]
CFPB ANNOUNCES FAIR LENDING PRIORITIES FOR 2017
On the heels of the Fall 2016 semi-annual agenda, the CFPB’s Director of Fair Lending announced the areas the department will be focused on in the upcoming New Year. Three areas of interest for this department of the Bureau in 2017 will be: Redlining – the Bureau will continue to evaluate whether lenders have intentionally avoided lending in minority neighborhoods. Mortgage and Student Loan Servicing – the CFPB will determine whether borrowers who are behind […]
LEP – THE NEXT BIG THING?
On September 15, 2016 the Department of Housing and Urban Development published guidance on Fair Housing Act Protections for Persons With Limited English Proficiency. The guidance applies to your role as a mortgage lender, and your role as a landlord, if applicable. Limited English Proficiency (LEP) refers to a person’s limited ability to read, write, speak, or understand English. Questionable practices include refusing to allow an LEP borrower to have mortgage documents translated, or refusing […]
REVISED SMALL ENTITY COMPLIANCE GUIDE FOR MORTGAGE SERVICING RULES
On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]